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FAA IR time towards CB-IR

Good evening

My goal is the CB-IR, which requires 50h PIC under IFR in order to skip the theory exams and other requirements. I am just shy of 50h PIC time under IFR, which I logged in the USA. However, this time includes dual instruction towards my initial FAA IR. Simple question: Can I count all my FAA PIC hours, or only the hours after I got my IR? I heard rumors that I can’t, but of course I like my opinion better and this is my reasoning:

EASA definition of PIC according to FCL.015: “Pilot-in-command” (PIC) means the pilot designated as being in command and charged with the safe conduct of the flight.
- I was indeed designated as PIC and charged with those duties.

AMC1 FCL.050 Recording of flight time: (b) Logging of time: (1) PIC flight time: (i) (ii) the holder of a licence may log as PIC time all of the fligh time during which he or she is the PIC;
- I was holder of a licence and I was PIC. The instrument rating is not a licence so it can’t be a requirement in order to log PIC under IFR according to this rule.

Am I correct or did I miss something?

Thank you! :-)

Last Edited by ArcticChiller at 20 Sep 17:08

For what it’s worth, I (and probably almost everyone who went CB-IR route) used the time logged with the IR(R) for CBIR.
Also, I don’t think when something asks PIC time, you differentiate between PIC time after you had your licence or not. Your first solo would count.

Bolded what I think is relevant. Whether you have a licence or not is irrelevant I would claim. If you are PIC, you log and count PIC, but you can only be PIC under certain conditions. I think alone in the plane is always PIC.

Logging of time:
(1) PIC flight time:
(i) the holder of a licence may log as PIC time all of the flight time during which he or she is the PIC;
(ii) the applicant for or the holder of a pilot licence may log as PIC time all solo flight time, flight time as SPIC and flight time under supervision provided that such SPIC time and flight time under supervision are countersigned by the instructor;

For those converting from an FAA IR, EASA won’t recognise IFR PIC time before you have qualified – it needs to be after the FAA IR checkride. This is different from those taking the normal CB-IR route with theory exams, where time learning towards IR(R) and subsequent solo IFR time will count.

EGBJ, United Kingdom

After DavidC’s comment, reading a bit more the regulations (I find it quite hard to find the most up to date one, as a part-FCL google will find one from 2011 and I guess all the rest comes as amendments. Any place where one could find just the “up to date” document?)

David, I see the EASA requirements as:
8. Applicants for the competency-based modular IR holding a Part-FCL PPL or CPL and a valid IR issued in compliance with the requirements of Annex 1 to the Chicago Convention by a third country may be credited in full towards the training course mentioned in paragraph 4. In order to be issued the IR, the applicant shall:
(a) successfully complete the skill test for the IR in accordance with Appendix 7;
(b) demonstrate to the examiner during the skill test that he/she has acquired an adequate level of theoretical knowledge of air law, meteorology and flight planning and performance (IR); and
(c) have a minimum experience of at least 50 hours of flight time under IFR as PIC on aeroplanes.

I find the bolded statement above conflicting with the one (also from some EASA document) from my previous post (about when you should log PIC). Not trying to push my point, as not a lawyer, but just curious as to how they decide that it doesn’t count. Is it someone at the CAA doing their interpretation, or some other point I might have missed (/ not put here)

I suspect the intent was not to make the FAA IR training route too attractive ;)

From reading the regs you quoted, you might argue that time flown as PIC after you gain an IR(R) would also count. I would think this would only be in the UK and exclude any instructional flights.

But this is only my opinion and worth what you paid for it.

EGBJ, United Kingdom

Oh, and the one place for UK regs is CAP804 – latest edition found at www.caa.co.uk/cap804

But as explained there, the latest edition is out of date and will be updated to reflect the latest UK ANO changes soon.

Last Edited by DavidC at 20 Sep 19:59
EGBJ, United Kingdom

I interpreted this reg as IFR time (block to block time under sn IFR flight plan) after having the FAA rating.
See http://www.abeam.be/easa_ir/
I admit that i had the luxury of taking this position because I did have that time logged. My interpretation might have been different if I didn’t.

Why not asking your CAA?

Abeam the Flying Dream
EBKT, LFQQ western Belgium, north France, Belgium

DavidC wrote:

From reading the regs you quoted, you might argue that time flown as PIC after you gain an IR(R) would also count. I would think this would only be in the UK and exclude any instructional flights.

I did count some of my PIC time (done under IR(R)) for the 40 hours. I also counted the instruction from the IR(R) for the minimum 25h flight instruction, which left me only having to do 10 at an ATO (and did a bit more, my instrument flying was a bit rusty)

For sure I will ask the CAA, just wanted to sharpen my knowledge, so I know there’s no goldplating. The time I count is all flown on IFR flight plans and flown as PIC, even according to the FCL definition. I understand why EASA would try to make the FAA IR route less attractive, but it isn’t clearly reflected in the rules/AMC as far as I can tell. Thanks for the inputs.

I suspect the intent was not to make the FAA IR training route too attractive ;)

Totally and obviously so….

The IFR time as PIC requirement is there to make the FAA PPL/IR in Arizona (etc) unattractive to the average European ATPL student.

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Shoreham EGKA, United Kingdom
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